The U.S. Treasury Department and IRS today released for publication in the Federal Register a notice of proposed rulemaking (REG-120232-17 and REG-120233-17) or proposed regulations to implement the centralized partnership audit regime, as enacted in 2015.
Read the proposed regulations [PDF 336 KB]
The purpose of this report is to provide text of these proposed regulations.
The new centralized partnership audit regime generally is effective for partnership tax years beginning after December 31, 2017. Temporary and proposed regulations released in August 2016 provided rules for an election to apply the centralized partnership regime for tax years beginning after November 2, 2015, and before January 1, 2018.
Regulations proposed in June 2017 set forth rules to implement the new centralized partnership audit regime. However, the rules regarding how pass-through partners take into account adjustments under the alternative to payment of the imputed underpayment described in section 6226 and under rules similar to section 6226, under section 6227, were reserved. Read TaxNewsFlash-United States
Proposed regulations (November 2017) provide rules regarding the international provisions under the centralized partnership audit regime. Read TaxNewsFlash-United States
Today’s proposed regulations address how pass-through entities take into account adjustments:
These proposed regulations also provide rules under the new centralized partnership audit regime concerning:
Today’s proposed regulations supplement the June 2017 proposed regulations by implementing the administrative and procedural provisions of the new centralized partnership audit regime (sections 6231 through 6235).
The proposed regulations are scheduled to be published in the Federal Register on December 19, 2017. Comments and requests for a public hearing are due by a date that is 90 days after December 19, 2017.
© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.